Your customer or buyer is asking for ESG information about Madagascar supply chains. Here is what the regulatory environment requires — and what international buyers need from you.
Madagascar is the world's leading producer of natural vanilla (approximately 80% of global supply) and a significant producer of ilmenite (titanium ore), chromite, cobalt, nickel, and graphite. Madagascar is also a major source of cocoa, cloves, and seafood for EU markets. The island's extraordinary biodiversity — including approximately 90% of its wildlife found nowhere else on Earth — makes deforestation and habitat destruction critical ESG issues. Madagascar faces significant governance challenges and is classified as a least developed country (LDC). ESG compliance pressure comes primarily from EU buyers subject to CSRD and CSDDD, the EU Deforestation Regulation (for cocoa), and the EU Battery Regulation (for graphite and cobalt/nickel from the Ambatovy mine).
Key regulations in Madagascar — ESG Supplier Guide
EU CSRD — Supply Chain Reporting Requirements
Malagasy vanilla, cocoa, seafood, and mineral exporters supplying EU buyers are exposed to CSRD supply chain reporting requirements. EU buyers subject to CSRD must report on their supply chain sustainability, including Malagasy suppliers. Key ESG issues for Malagasy suppliers include: deforestation and biodiversity impacts (vanilla farming has driven significant deforestation in northeastern Madagascar), child labour in vanilla farming, and environmental management at mining operations.
EU CSDDD — Corporate Sustainability Due Diligence Directive
EU companies sourcing from Madagascar will be required under CSDDD to conduct human rights and environmental due diligence. Key human rights risks in Madagascar include: child labour in vanilla farming (children participate in pollination and harvesting), labour rights in mining operations, and community rights in areas affected by mining and agricultural expansion. Environmental risks include deforestation, biodiversity loss, and water management at mining sites.
EU EUDR — Cocoa and Timber
Madagascar is a cocoa producer (primarily in the Sambirano valley) and a source of timber. EU importers of Malagasy cocoa and timber must demonstrate that these commodities were not produced on land deforested after December 31, 2020. Madagascar's extraordinary biodiversity makes deforestation a critical concern — the island has lost approximately 90% of its original forest cover. Malagasy cocoa and timber exporters must implement geolocation data collection and deforestation verification systems.
EU Battery Regulation — Graphite, Cobalt & Nickel
Madagascar is a significant producer of natural graphite (used in battery anodes) and hosts the Ambatovy nickel-cobalt mine (operated by Sherritt International). The EU Battery Regulation requires due diligence on natural graphite, cobalt, and nickel supply chains. Malagasy graphite and Ambatovy nickel/cobalt exporters must demonstrate responsible sourcing, environmental management, and community rights compliance to EU battery manufacturers.
What this means for you as a supplier
Malagasy vanilla and cocoa exporters face CSRD supply chain reporting requirements from EU buyers. Vanilla exporters should address child labour risks and implement traceability systems. Cocoa exporters must prepare for EUDR geolocation requirements ahead of December 2026. Graphite and nickel/cobalt producers must comply with EU Battery Regulation due diligence. All Malagasy companies in EU supply chains face CSDDD due diligence from EU buyers from 2029.
Key dates
FY2024 (ongoing)
CSRD — large EU companies must report on supply chain sustainability including Malagasy suppliers
December 31, 2020
EUDR deforestation cut-off date — cocoa and timber produced on deforested land after this date is non-compliant
December 30, 2026
EUDR applies to large EU operators — Malagasy cocoa and timber exporters must demonstrate deforestation-free production
July 2029
CSDDD Phase 1 — largest EU companies must conduct supply chain due diligence including Malagasy suppliers
Vanilla: the world's most labour-intensive spice and its ESG challenges
Madagascar produces approximately 80% of the world's natural vanilla, primarily in the SAVA region of northeastern Madagascar. Vanilla is the world's second most expensive spice after saffron — each flower must be hand-pollinated within 12 hours of opening, and the curing process takes several months. The vanilla supply chain has significant ESG challenges. Child labour is documented in vanilla farming — children participate in pollination, harvesting, and processing. Vanilla price volatility (prices swung from $600/kg in 2018 to under $100/kg in 2020) creates poverty and instability in farming communities. EU confectionery and flavour companies sourcing Malagasy vanilla face CSRD supply chain reporting requirements and CSDDD due diligence obligations. Key certifications for Malagasy vanilla include Rainforest Alliance, Fairtrade, and organic certification. Traceability systems linking vanilla to specific farms are essential for EU buyer compliance.
Biodiversity: Madagascar's extraordinary natural heritage and deforestation crisis
Madagascar is one of the world's most biodiverse countries — approximately 90% of its wildlife is found nowhere else on Earth, including over 100 species of lemurs, 300 species of birds, and thousands of plant species. The island has lost approximately 90% of its original forest cover due to slash-and-burn agriculture (tavy), charcoal production, and logging. Deforestation continues at a significant rate, threatening Madagascar's unique biodiversity and contributing to climate change. The EU Deforestation Regulation (EUDR) applies to Malagasy cocoa and timber exports to the EU. EU importers must demonstrate that these commodities were not produced on deforested land. Madagascar's biodiversity makes it a priority country for international conservation organisations and development finance institutions. ESG investors and EU buyers are increasingly scrutinising the biodiversity impacts of Malagasy supply chains.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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